Ten years at Department of Conservation leaves me with many fond memories, especially when I see photos on Facebook of my old workmates out in the bush. This week it was releasing threatened native short-tailed bats near Ruapehu.
But it wasn’t always easy and fun during my time at DOC. There were a number of frustrations and DOC’s decision not to submit on Trans Tasman Resources’ application to mine the seabed off the coast of Patea has prompted memories of that sort.
Of course it’s not the first time DOC has taken a soft approach to their statutory advocacy role – DOC has recently been strongly criticised, taken to court even, for not prioritising conservation values regarding the proposed land swap as part of the controversial Ruataniwha dam proposal.
In this scenario, DOC has apparently said it is satisfied that it has made all the conservation gains it can by working privately with TTR – that doesn’t make sense to me. They certainly may have identified specific problems with the application and persuaded TTR to adapt their application – but that’s no guarantee.
The way the process works is that the Environmental Protection Agency makes the decision of whether to approve and sets the conditions to be met if it does go ahead. A critical step in that decision-making process is reviewing submissions and then discussing them with submitters, if they choose, at a hearing. DOC has declined to take part in that step, so has no way of ensuring its views are heard. They’ve also snubbed Taranaki iwi in this process – a short-sighted move given their Treaty obligations, strategic directions and direct commitments to partnership.
Of course sometimes DOC needs to be sensible in a resource-constrained world – it has to pick its battles. But is TTR’s proposal one of those to let go? Let’s examine it. If approved, it will be the first seabed mining in New Zealand, and it’s massive. The project is excavating 50 million tonnes of sand each year for 35 years from an area of 65 square kilometres. This is not a simple operation with known risks – it is the first of its kind here and is happening in an area we know little about.
How could it even be approved given that context? Unfortunately, the EPA’s legislation allows for a practice called “adaptive management”. That is the concept where operations are monitored so closely that if anything unexpected happens, they shut down and fix. Nice theory. Will it work in practice?
That is the nub – if approved, will there be sufficient, effective, underwater monitoring that picks up unacceptable impacts straightaway? What happens if it doesn’t work? What will be sacrificed? And how much trust is appropriate to place in private organisations where priority is a return to shareholders above all else? What is our experience with other commercial operators in the ocean around the world?
I fear “out of mind, out of sight” is reducing the weight applied to the precautionary principle. I can’t imagine a 65 square kilometre open cast mine operating in New Zealand, digging 11m deep, extracting the mineral, then dumping the rest back into a broken landscape – it is the 21st century.
Remember, it’s not just sand down there. There’s complex life on the seabed; rocks and reef structures are home to all sorts of marine life. And in contrast to dumping on land, the material returned to the seabed creates a plume of sediment. There’s a tricky debate over this plume, as TTR has approval to keep that content private, releasing only to those who sign a confidentiality waiver – it’s hard to have open debate in those circumstances.
We need DOC taking a strong and cautious role on behalf of New Zealanders who want our underwater heritage protected just as much the unique world we see above the waves. They now have time to revisit their decision not to participate, with an extension granted to all submissions until 14 November – I hope they do.
- · Check out www.kasm.org.nz for more info or to make your own submission.